DATA PRIVACY AR BUG DEFENDER

Letztes Update: 16. January 2026

This Privacy Policy explains how your personal data is collected and processed by Villa Hirschberg Online GmbH (‘VHO’) when you use the game ‘AR Bug Defender’ (the ‘Game’).

The game is free to play. In order to maintain high quality and a great gaming experience, we process information from and about you, primarily to improve the overall experience with the game and to support internal processes.

We update this privacy policy from time to time. If we make any changes, we will notify you by updating the date at the top of this privacy policy. In addition, depending on the nature of the changes, we will notify you separately or request your renewed consent. We encourage you to read the privacy policy each time you access the game so that you are always up to date on how we process your personal data and how you can protect your privacy.

Collecting information

Information you provide to us

This privacy policy applies solely to the game. If you submit any information to VHO via our website or other sites or services, please refer to the VHO privacy policy (available at www.villa-hirschberg.de) or other privacy policies, as applicable, for information on how we collect, use and share such information.

When you access or use this game, you provide us with the following information:

• none:

Information we collect automatically about the game

When you access or use the app, we automatically collect general information about you, including:
• device information: We collect information about the device you use to access the app (i.e. the device ID and
advertising ID).

Use of information – purpose and legal basis

We use information about you for the following purposes and in accordance with the following legal bases, in each case in relation to the specified type of personal data:

Device and consumer information

– are processed:
a. to provide you with the desired products and services and to send you relevant information as requested by you or as agreed with you;
b. to provide and maintain the game and the gaming experience; and
c. to send you technical notices, updates and security alerts, as well as maintenance-related and administrative messages;
Our processing for the above purpose is necessary to fulfil the contract concluded with you, namely to support the execution of the game, to provide the desired products and services, and to enable the maintenance and updating of the game, see Article 6(1)(b) GDPR.
d. to provide you with news and information about the game that we believe may be of interest to you;
e. to personalise and improve the game and to offer tailored content and features;
f. to monitor and analyse trends, usage patterns and activities related to the game; and
g. to provide children (as defined by the GDPR in the EU, COPPA in the US, and the corresponding applicable legislation in other jurisdictions) with appropriate contextual advertising in the game.

Storing information

VHO will store your personal data for as long as necessary to provide you with the game or to fulfil the other purposes mentioned above, unless longer storage is necessary to assert, exercise or defend a legal claim or to comply with applicable legal requirements, including accounting regulations.
VHO will delete your personal data as soon as it is no longer necessary for the purposes mentioned above.
Your personal data will be deleted or anonymised as soon as it no longer serves any of the above purposes, and in any case no later than three (3) years after your interaction with VHO has ended.

Children

The game is intended for a general audience.
VHO does not process personal data for behavioural advertising to children. If such data has been processed without VHO’s knowledge, VHO will take appropriate measures to stop the processing and delete any such data from VHO’s archives as soon as it becomes aware of the incident.
If you have any further questions regarding VHO’s data protection practices with regard to children who do not meet the applicable minimum age, please contact us at bug.defender@villa-hirschberg.de.

Transfer to third countries

In connection with data processing, we will transfer your personal data to recipients in the United States under certain conditions. The United States has been classified as an unsafe third country by the European Commission.
However, we only transfer personal data to entities in third countries that have taken appropriate security measures to ensure that their level of data protection complies with these data protection provisions and applicable law.
Therefore, data transfers only take place if
• the recipient is certified under the principles of data protection in accordance with the US-EU Privacy Shield Framework (‘Privacy Shield’) (organisations certified under the Privacy Shield can be found at www.privacyshield.gov), or
• we have agreed with the recipient on the standard data protection clauses adopted by the Commission, which are considered sufficient safeguards with regard to the protection of privacy and the fundamental rights and freedoms of individuals (please contact VHO if you would like to receive a copy of these clauses).

Safety

VHO takes appropriate measures to protect information about you from loss, theft, misuse and unauthorised access, disclosure, alteration and destruction.

Your rights

If you wish to exercise one or more of the rights described below, please contact us at any time by email at bug.defender@villa-hirschberg.de.
We will process and respond to your requests without delay and in any case within one month of receiving your request, unless the complexity of the request requires a longer period. In this case, our response period may take up to a total of three months, as permitted by Article 12 of the GDPR.

Right to information

You have the right to request information about your data processed by us, see Article 15 GDPR, including information about:
• the purpose of the processing
• the categories of personal data concerned
• the recipients or categories of recipients to whom the personal data has been or will be disclosed
• the envisaged storage period of the personal data
In addition, you have the right to obtain a copy of the personal data processed. Please note that access may be restricted by intellectual property rights or trade secrets.

Right of objection

You have the right to object to the processing of your personal data on grounds relating to your particular situation if this data is processed on the basis of the balancing of interests provision in Article 6(1)(f) GDPR, see Article 21 GDPR.
In this case, we will cease processing unless there are compelling legitimate grounds for the processing that override your interests, rights and freedoms
or unless the processing is necessary for the establishment, exercise or defence of legal claims.
You have the right to object to the processing of your personal data for direct marketing purposes at any time. We will cease processing your personal data for this purpose after you object. Please note that your user licence to use the game will automatically expire if you exercise this right.

Right to rectification and erasure

You have the right to rectify inaccurate personal data, see Article 16 GDPR.
In addition, you have the right to erasure of your personal data for one of the following reasons, see Article 17 GDPR:
• The personal data is no longer necessary for the purposes for which it was collected or otherwise processed.
• You withdraw your consent and there is no other legal basis for the processing.
• You have objected to the processing and there are no overriding legitimate grounds for the processing.
• The personal data has been unlawfully processed.
• The erasure of the personal data is necessary to comply with a legal obligation under Union or Member State law.
• The personal data has been collected in relation to information society services offered.
Please note that your right to erasure may be limited if the data is necessary for compliance with legal obligations or for the establishment, exercise or defence of legal claims.

Right to restriction of processing

You have the right to request the restriction of processing under certain circumstances, see Article 18 GDPR. If you are entitled to the right to restriction of processing, we will only process your data with your consent or for the establishment, exercise or defence of legal claims or for the protection of a person or for reasons of important public interest.

Right to withdraw consent

If we have asked for your consent to process your data, you have the right to withdraw your consent at any time, see Article 7 GDPR.
If you withdraw your consent, we will stop processing the data for which you have withdrawn your consent, unless we have a legal obligation to process some or all of your data.
Please note that your user licence for using the app will automatically expire if you withdraw your consent.
The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal.

Right to data portability

You have the right to receive the personal data you have provided and which we process in a structured, commonly used and machine-readable format, and the right to transmit this data to another controller if the processing is based on consent or contract performance, see Article 20 GDPR.

Contact and complaints

VHO has the following contact information:

Villa Hirschberg Online GmbH
Address: Danziger Straße 118, 10405 Berlin, Germany
Email: info@villa-hirschberg.de.

If you wish to lodge a complaint about the processing of your personal data, you have the right to lodge a complaint with the competent supervisory authority.